ML19324B436

Responds to NRC 890927 Ltr Re Violations Noted in Insp of License R-116.Corrective Actions:Reactor Daily Startup Checklist Modified to Require Reactor Operators to Verify Completion & Signoff of Appropriate Checklists

ML19324B436
Person / Time
Site:	University of California - Irvine
Issue date:	10/25/1989
From:	Tien C CALIFORNIA, UNIV. OF, IRVINE, CA
To:	Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML19324B437	List: ML19324B436 ML19324B439
References
NUDOCS 8911060317
Download: ML19324B436 (3)

Text

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RY1 fA IPO NI 717 October 25th,1989  ;

U.S. Nuclear Regulatory Comraission, Region V, ,

1450 Maria Lane, Suite 210, i y

Walnut Creek, CA 94596 l i

[ Attention: Director Ross A. Scarano i Docket 50-326 i License R 116 Re: Reply to a Notice of Violation dated Sentember 27th.1989

' Gentlemen:

With respect to the referenced Notice of Violation we respond as follows: l Item A. " Reactor operations continued even though none of t.he Operator Monthly Maintenance checklists had been reviewed for the penod August through December .988." l r

(1) Comment:

As noted in remarks to the inspector this was an oversight on the part of the Reactor Supervisor and Assistant Reactor Supervisor, even though all maintenance iteins had been completed on schedule, and such a report made orally to the administrative staff.

(2) Corrective steps: i The reactor daily start up checklist has been modified to require reactor operators to verify the

• completion and sign off of appropriate checklists prior to any daily operation. This has been ,

implemented.  ;

(3)Further action:

Future operator training and requalification discussionrovill include reference to the importance of sig>off on documentation and additional review of riecessary conditions for continued operation. The staff, and the Reactor Operations Committee will study possible revision of the Operating Procedures so that single review may be all that is needed to assure compliance.

(4) Full Compliance:

l Compliance with existing procedures is considered to have been accomplished. ,

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l- Item 11. "The Reactor Operations Committee failed to meet during the period August 19,1988, to i January 30,1989."

(1) Comment:

This item was reponed to NRC by letter dated May 5th,1989. The reasons and the corrective g${' action were desenbed in the letter. A copy is attached for your information.

(2)Conective steps:

w tgJ The steps taken are described in the attached letter.

I (3)Further action:  :

tM No further action is planned, except for consideration being given to requesting an amendment to

.r this Technical Specification item to reduce the frequency of required meetings.

%g (4) Full Compliance:

f Compliance with existing requirements is considered to have been accomplished.

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• i Item C.a. " Contrary to the above requirement the licensee did not document additional training  !

provided to a senior reactor o

j. requalification examination." perator who scored less than 80% on two sections!

(1) Comment' In his detailed report on this item (Inspection Report, page 7, line 20), the inspector noted: "The Reactor Supenisor stated that the two sections of the eumbiation were discussed with the SRO i as compensatory training. " This fact was documented by a note made on the front cover of the senior oprator's examination script maintained in the files as " Reviewed with PJR". The operator s initials are PJR. At the time this was felt to be both sufficient training and  ;

documentation.

(2) Corrective steps: -

This issue has been noted by the Reactor Supervisor, who acts as the training and requalificaticm  :

dinctor. Future records '>.:11 be made clearer.  !

(3)Further action: [

None contemplated.

(4) Full Compliance:

This issue did not ariar with the 1989 requalification, where all scores were satisfactory. The difference may have been because of a deliberate effort to make the examin'ition even more

" performance based".

Item C.b. " Contrary to the above requirement the heactor Supenisor did not conduct an operating  ;

test for evaluating operators or senior operators during the period of 1988 and 1989 to the date of the inspection."  ;

(1)Conunent:

At this facility there have only been two licensed senior operators and one licensed operator during the period since 1987. One of the senior operators is the Reactor Supervisor, and the other acts as Assistant Reactor Supervisor. All three individuals are in close collaboration regarding operation, scheduling, maintenance, safety and all operational issues. Thus the other operators are often under direct assessment by the Reactor Supervisor and there has never been any question of their competence to operate the reactor safely. However, documentation of this ,

contact is weak or non existent.

(2)Conective steps:

None taken at this time. '

(3) Future Actions:

The Reactor Supervisor as training coordinator will implement a diary ofinctor operator ineetings, discussions, and observations of performance for each licensed individual.

Each operator will share responsibility for entries, although it will clearly be the Supenisor's responsibility for the upkeep of this dir.ty This lc,g should provide the necessary documentation for ongoing requalification. In addition, thi,0.eactor Operations Committee will discuss the possibthty of applying for a license amendmee obtam permission for a more flexible qu ifi tion progrant better suited to the needs of our cility than that imposed by NRCin (4) Full Compliance:

• The diary system should be fully implemented by the end of this year (December 31st,1989).

We hope this will satisfy full compliance as facility and depanment resources do not pennit arovis.on of additional full coursework for operators. Changes in the program will take much Longer to be drafted and approved.

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Additional Item:

Your notice of transmittal asks for comments on "the level of management attention necessary to assure continued safe operations". We are pleased that you agire that such matters "do not represent a significant safety concem at this time". We comment as follows:

The Chemistry Depanment t.nd the School of Physical Sciences are currently reviewing the staffing sit uation at the facility. There had been a plan to combine a position of reactor operator and reactor hedth physicist, with other chemistry depanmental duties, into a full time staff position. The individual in mind for this position is no longer available. Whether to pursue this or some other model ofimproving paid staffing at the facility is currently under review, in the meantime, the Reactor Supervisor has made a commitment to assign additional hours of his time to facility management and operations, lie and the Assistant Reactor Supervisor ere discussing reassignment of cenain tasks between them to provide more assurance of timely documentation.

It is anticipat:d tl.at plans will be firm by January,1990. Meanwhile, the facility will continue to be operated safely under existing arrangements, but with closer attention to details of documentation, which appear to be the major issue for concern. Review by outside individuals from E,li&S will also pay closer attendon to details of documentation. They will be assisted in this task by newly created audit checklists.

Sincerely, Chang in Tien, Executi e Vice-Chancellor cc: 11.W. Moore, Dean, Physical Sciences M.C. Caserio, Chair, Chemistry u V.P. Guinn, Chair, Reactor Operations Committee 1 F.S. Rowland, Reactor Administrator l G.E Miller, Reactor Supervisor l

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